OT:RR:NC:N2:349
Ms. Yaping Shan
Hangzhou Joyce Household Textiles Co.,Ltd.
No.2675 Xinluo Road, Xintang Street, Xiaoshan District,
Hangzhou 311201
China
RE: Country of origin determination for pillows; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Shan:
This is in reply to your letter dated June 20, 2025, requesting a country of origin determination for pillows,
which will be imported into the United States. In lieu of samples, pictures and product descriptions were
provided.
FACTS:
The subject pillows have an outer shell made of 100 percent cotton woven fabric and are stuffed with either
100 percent polyester fiber or feather and down filling. You state the edges are finished with self-fabric
piping that is dyed blue and measures less than 6.35 mm. The LaCrosse Loftaire Down Alternative Chamber
and LaCrosse Down & Feather Chamber pillows contain a self-fabric lining that creates three separate
chambers. The LaCrosse Loftaire Down Alternative Chamber pillows, 11214B-STD-White and
11214B-K-White, contain a mixture of 1.5 and 4 denier polyester fiber in the outside chambers and 4 denier
polyester fiber in the middle chamber. The LaCrosse Down & Feather Chamber pillows,
11213B-STD-White and 11213B-K-White, contain down in the outside chambers and feathers in the middle
chamber. The pillows are imported in Standard size, 20 × 26 inches, and King size, 20 × 36 inches. The
pillows are available in the following SKU and product numbers:
Name SKU# Product #
LaCrosse Loftaire Down Alternative Pillow 11209A-STD-White 25DAPST01
Soft Standard
LaCrosse Loftaire Down Alternative Pillow 11209A-K-White 25DAPSK02
Soft King
LaCrosse Loftaire Down Alternative Pillow 11209B-STD-White 25DAPMS01
Medium Standard
LaCrosse Loftaire Down Alternative Pillow 11209B-K-White 25DAPMK02
Medium King
LaCrosse Loftaire Down Alternative Pillow 11209C-STD-White 25DAPFS01
Firm Standard
LaCrosse Loftaire Down Alternative Pillow 11209C-K-White 25DAPFK02
Firm King
LaCrosse Loftaire Down Alternative Chamber 11214B-STD-White 25DACPS01
Pillow STD
LaCrosse Loftaire Down Alternative Chamber 11214B-K-White 25DACPK02
Pillow King
LaCrosse Down & Feather Pillow 11205A-STD-White 25DPS01
Soft STD
LaCrosse Down & Feather Pillow 11205A-K-White 25DPK02
Soft King
LaCrosse Down & Feather Pillow 11205B-STD-White 25DPM01
Medium STD
LaCrosse Down & Feather Pillow 11205B-K-White 25DPM02
Medium King
LaCrosse Down & Feather Pillow 11205C-STD-White 25DPF01
Firm STD
LaCrosse Down & Feather Pillow 11205C-K-White 25DPF02
Firm King
LaCrosse Down & Feather Chamber Pillow 11213B-STD-White 25DCPS01
STD
LaCrosse Down & Feather Chamber Pillow 11213B- K-White 25DCPK02
King
The manufacturing operations for the pillows are as follows:
PAKISTAN
The face, back and lining cotton fabric is woven.
The fabric is exported on rolls to China.
CHINA
Polyester staple fiber is manufactured.
The face, back and lining fabric is bleached and dyed.
Piping is formed.
The fabric is cut and sewn.
The pillow is filled with Chinese-sourced 100 percent polyester fiber or feathers and down and sewn
closed.
The pillows are packaged and exported to the United States.
ISSUE:
What is the country of origin of the subject merchandise?
COUNTRY OF ORIGIN - LAW AND ANALYSIS:
Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on
December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs
laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or
withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as
Congress’s expression of substantial transformation as it relates to textile and apparel products. Section
102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin
of a textile or apparel product shall be determined by the sequential application of the general rules set forth
in paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c).
Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory,
or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not
wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section
102.21 is inapplicable.
Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or
insular possession in which each of the foreign materials incorporated in that good underwent an applicable
change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of
this section:”
Paragraph (e) in pertinent part states,
The following rules shall apply for purposes of determining the country of origin of a textile or
apparel product under paragraph (c)(2) of this section:
HTSUS Tariff shift and/or other requirements
9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of
this section, the country of origin of a good classifiable under subheading
9404.90 is the country, territory, or insular possession in which the fabric
comprising the good was formed by a fabric-making process.
The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “any manufacturing operation that begins
with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a
textile fabric.”
The subject pillows are not classified among the paragraph (e)(2) exceptions to the above tariff shift rule. As
the fabric for the pillows is formed by the fabric-making process in a single country, that is, Pakistan, as per
the terms of the tariff shift requirement, country of origin is conferred in Pakistan.
HOLDING:
The country of origin of the LaCrosse Loftaire Down Alternative and LaCrosse Down & Feather pillows is
Pakistan in accordance with 19 CFR 102.21(c)(2).
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Kim Wachtel at [email protected].
Sincerely,
James Forkan
Acting Director
National Commodity Specialist Division